SecProbe.io

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                      [KENNEDY & BARIS, L.L.P. LETTERHEAD]

                                September 9, 2005

VIA EDGAR
Ms. Joyce Sweeney
Securities and Exchange Commission
450 5th Street, NW
Mail Stop 4561
Washington DC 20549

     RE:   CommerceFirst Bancorp, Inc., Commission File No. 0-51104
           Form 10-KSB for the period ended December 31, 2004

Dear Ms. Sweeney:

      On behalf of CommerceFirst Bancorp, Inc. (the "Company"), we hereby
enclose the Company's response to your comment letter dated August 30, 2005 in
respect of the Company's Annual Report on Form 10-KSB for the year ended
December 31, 2004. For convenience we have preceded each of the Company's
responses with the Commission staff's comment.

EXHIBIT 13 - 2004 ANNUAL REPORT

CONSOLIDATED FINANCIAL STATEMENTS

NOTE 10 - INCOME TAXES, PAGE 28

1.    WE NOTE THAT YOU RECORDED A $944 THOUSAND REDUCTION OF YOUR VALUATION
      ALLOWANCE DURING THE FISCAL YEAR 2004, REDUCING IT TO ZERO. PLEASE REFER
      TO PARAGRAPHS 21 - 23 OF SFAS 109 AND PROVIDE US WITH YOUR COMPREHENSIVE
      ANALYSIS OF HOW YOU DETERMINED THE AMOUNT OF YOUR DEFERRED TAX ASSET
      VALUATION ALLOWANCE AS OF DECEMBER 31, 2003 AND DECEMBER 31, 2004.

      The determination by the Company in the third quarter of 2004 to reduce
      the valuation allowance relating to the deferred tax asset was based on
      the conclusion of Company management and the audit committee of the Board
      of Directors, reached in consultation with the independent auditor as to
      the requirements of generally accepted accounting principles, that as of
      that time it was more than likely than not that the deferred asset would
      be recognized, in accordance with Paragraph 17(e) of SFAS 109, and in
      light of the applicable factors and examples discussed in paragraphs 21 -
      23. The valuation allowance was subject to repeated analysis and
      discussion among Company management, the audit committee and the Company's
      independent auditor. In reaching this conclusion the positive and negative
      evidence bearing on the question of whether the Company would be able to
      utilize the deferred asset prior to its expiration was considered. In
      particular, the following facts and circumstances were considered and
      understood:
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Ms. Joyce Sweeney
September 9, 2005
Page 2

      o  The Company had then achieved sustained core operating profitability in
         each month over a fifteen month period, including earnings of
         approximately $198 thousand for the first six months of 2004, and at
         the then current rate of earnings, would utilize the net operating loss
         over a period of two and a half to three years.

      o  The Company had received regulatory approval of its application to
         establish a second banking office, in Prince George's County, Maryland,
         which opened on September 30, 2004. The second office would serve to
         support a loan and business development officer hired in February 2004.
         The second office would permit a focus for additional expansion of
         development efforts in Prince George's, and was expected to result in
         expanded rates of growth and growth in income.

      o  The Company was engaged in efforts to raise approximately $10 million
         in additional capital in an underwritten offering or a combination
         rights offering/underwritten offering, which would permit the Company
         to maintain a higher level of loans and investment securities, an
         increased lending limit, and permit the Bank to compete more
         effectively against larger institutions, and as such was expected to
         result in asset growth and higher income. The Company ultimately raised
         approximately $10 million in the combined offering, which closed in the
         first quarter of 2005. The additional capital, combined with
         anticipated earnings and options exercises, was expected to permit
         continued operations and growth for a period of at least two to three
         years before additional capital would become necessary.

      o  The strength and experience of senior management, business development
         officers and the Board of Directors.

      Based on the foregoing positive factors, the Company believed that there
      would be sufficient taxable income in the carryforward period to utilize
      the deferred tax asset, and in accordance with paragraph 21 of SFAS 109,
      and with the concurrence of its independent auditor, determined to
      eliminate the valuation allowance.

      We note that the initial determination to effect the recognition was made
      in August 2004, prior to the unanticipated deterioration of an
      approximately $960 thousand loan relationship that resulted in a special
      provision for loan losses of $350 thousand made on September 16, 2005. The
      impact of the special provision, credit quality issues relating to this
      loan and the loan portfolio and allowance for loan losses in general on
      the prior determination to effect the reduction in the valuation allowance
      was considered, and it was determined that the unique circumstances
      surrounding the deterioration of this relationship did not materially
      alter the expectation that the Company would have sufficient earnings
      within a three year timeframe to utilize the deferred tax asset. The
      Company was ultimately profitable in each quarter of 2004, and had pre-tax
      profitability of $227 thousand, including the effect of the September 2004
      loan provision.

      For the year ended December 31, 2003, the Company engaged in a comparable
      analysis and discussions among management, the audit committee and the
      independent auditor. In respect of that year, the following facts and
      circumstances were considered and understood:

      o  The Company has a history of cumulative losses from its date of
         organization though the end of the year ended December 31, 2002, which
         then stood at approximately $(2.5 million). As noted in paragraphs 23
         and 103 of SFAS 109, a cumulative loss in recent years is a significant
         piece of negative evidence that is difficult to overcome.

      o  The Company, while achieving its first month to month profitability in
         January 2003, was only marginally profitable on a monthly basis, and
         had a net profit of only $142 thousand in 2003, reflecting a return on
         assets of 0.33% and a return on equity of 2.5%.
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Ms. Joyce Sweeney
September 9, 2005
Page 3

      Based on the foregoing factors, the Company did not believe that there was
      sufficient quality or quantity of sustained earnings or other positive
      evidence to overcome the negative factors, and therefore, with the
      concurrence of its independent auditors, determined to maintain a
      valuation allowance equal to 100% of the deferred tax asset (other than
      the portion related to net unrealized gains on available for sale
      securities) to reduce the value of the deferred tax asset. The Company and
      its auditors did not believe a partial valuation allowance was
      appropriate, given (i) the principal component of the deferred asset was
      the net operating loss carryforward, and (ii) the conclusion that there
      was insufficient basis to say that it was more likely than not that the
      Company would be able to utilize the deferred asset in the carryforward
      period.

ITEM 8A - CONTROLS AND PROCEDURES, PAGE 11

2.    WE NOTE YOUR DISCLOSURE THAT YOUR PRINCIPAL EXECUTIVE OFFICER AND
      PRINCIPAL FINANCIAL OFFICER HAVE CONCLUDED THAT THE COMPANY'S DISCLOSURE
      CONTROLS AND PROCEDURES WERE ADEQUATE. IT DOES NOT APPEAR THAT YOUR
      CERTIFYING OFFICERS REACHED A CONCLUSION THAT YOUR DISCLOSURE CONTROLS AND
      PROCEDURES ARE EFFECTIVE. PLEASE TELL US YOUR CERTIFYING OFFICERS'
      CONCLUSIONS REGARDING THE EFFECTIVENESS OF YOUR DISCLOSURE CONTROLS AND
      PROCEDURES AS OF DECEMBER 31, 2004. PLEASE REVISE YOUR DISCLOSURES IN
      FUTURE FILINGS TO ADDRESS YOUR OFFICERS' CONCLUSION REGARDING THE
      EFFECTIVENESS OF YOUR DISCLOSURE CONTROLS AND PROCEDURES.

      On behalf of the Company, we hereby advise you that the Company's
principal executive and principal financial officer determined that the
Company's disclosure controls and procedures were effective in ensuring material
information required to be disclosed was recorded, processed, summarized, as of
December 31, 2004. The Company will revise its disclosure in filings made after
the date of this letter to address the officers' conclusions as to the
effectiveness of the disclosure controls and procedures.

      Enclosed with this letter please find the requested written
acknowledgement statement from the Company.

      Please do not hesitate to contact the undersigned at 301.229.3400 (x18),
by fax at 301.229.2443, or by email at nmgruber@kblbanklaw.com, if you have any
questions regarding this response, have any further comments, or require further
information.

                                   Sincerely,

                                   /s/ Noel M. Gruber

                                   Noel M. Gruber

cc:   Sharon Johnson (via telecopier 202.722.9208)
      Richard Morgan
      Lamont Thomas
      Mark Welsh

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                           COMMERCEFIRST BANCORP, INC.
                           1804 WEST STREET, SUITE 200
                            ANNAPOLIS, MARYLAND 21401

                                September 8, 2005

VIA EDGAR
Ms. Joyce Sweeney
Securities and Exchange Commission
450 5th Street, NW
Mail Stop 4561
Washington DC 20549

      RE:   CommerceFirst Bancorp, Inc., Commission File No. 0-51104
            Form 10-KSB for the period ended December 31, 2004

Dear Ms. Sweeney:

      In connection with the response of CommerceFirst Bancorp, Inc. (the
"Company") to the comment letter of Commission staff dated August 30, 2005
relating to the Company's Form 10-KSB for the year ended December 31, 2004 (the
"Filing"), the Company, by its duly elected and currently serving officer, does
hereby acknowledge that:

         o  The Company is responsible for the adequacy and accuracy of the
            disclosure in the Filing;

         o  Staff comments or changes to disclosure in response to staff
            comments do not foreclose the Commission from taking any action with
            respect to the Filing; and

         o  The Company may not assert staff comments as a defense in any
            proceeding initiated by the Commission or any person under the
            federal securities laws of the United States.

                                      Sincerely,

                                      COMMERCEFIRST BANCORP, INC.

                                      By: /s/ Richard J. Morgan
                                          --------------------------------------
                                          Richard J. Morgan
                                          President and Chief Executive Officer
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